BNKA

1. INTRODUCTION AND PLATFORM OWNERSHIP

These General Terms and Conditions (“General Terms”) govern the access to and use of the BNKA technological platform (the “Platform”), including its website, mobile applications and related digital interfaces.
The Platform is owned by Neoxpat Limited, a company incorporated under the laws of Cyprus (“Neoxpat” or the “Platform Owner”). Neoxpat is responsible for the ownership, development, maintenance, security and governance of the Platform as a technological infrastructure.
The Platform is a technology layer that enables users to access services provided by third-party regulated entities or local operating entities, depending on the user’s country or region.
Neoxpat does not itself provide banking services, payment services, electronic money services, investment services, credit services or any other regulated financial services, unless expressly stated otherwise in jurisdiction-specific terms.

2. STRUCTURE OF THESE TERMS

These General Terms apply globally to all users of the Platform.
Depending on the user’s country of residence or the services accessed, additional terms and conditions (“Local Terms”) may apply. Local Terms are published separately by country or region and identify the regulated service provider(s), applicable licenses, services offered and local regulatory requirements.
In the event of any conflict, the applicable Local Terms shall prevail over these General Terms.

3. SCOPE OF THE PLATFORM

The Platform provides a digital environment that may allow users to:
- register and create a user profile;
- complete identity verification and compliance procedures;
- view information, balances or transaction history;
- submit requests or instructions to service providers;
- access customer support and informational content.
The Platform itself does not constitute a bank account, payment account, electronic wallet or financial product.

4. MODULAR SERVICE MODEL

Services accessible through the Platform are provided on a modular basis by independent entities, depending on jurisdiction and regulatory permissions.
The Platform may facilitate access to, without limitation:
(a) Crypto-asset related services, such as the purchase, sale, exchange or custody of crypto-assets, where such services are provided by an entity duly authorized as a virtual asset service provider or equivalent under applicable law;
(b) Fiat currency and payment-related services, such as payment accounts, transfers, cards, technical account identifiers (including virtual IBANs), where such services are provided exclusively by duly authorized banks, payment service providers or electronic money institutions;
(c) Other financial or non-financial services offered by local partners or third parties in accordance with applicable law.
The Platform acts solely as a technological interface and does not become a contractual counterparty to regulated services, unless expressly stated in the applicable Local Terms.

5. LOCAL SERVICE PROVIDERS

For each country or region, the Local Terms identify:
- the entity or entities providing regulated services;
- the nature and scope of such services;
- the applicable regulatory framework and supervisory authority;
- consumer protection rules, limits and fees.
Users are deemed to contract directly with the local service provider for regulated services, under the applicable Local Terms.

6. USER ELIGIBILITY AND REGISTRATION

To use the Platform, users must be at least eighteen (18) years old and have full legal capacity.
Users must complete onboarding, identity verification and compliance procedures as required by applicable laws, regulations and the relevant local service provider.
Neoxpat and local service providers reserve the right to accept or reject user registrations and to request additional information at any time.

7. USER OBLIGATIONS

Users agree to:
- provide accurate, complete and up-to-date information;
- use the Platform lawfully and in good faith;
- comply with all applicable laws, regulations and Local Terms;
- not use the Platform for illegal, fraudulent or prohibited activities.
Users are responsible for maintaining the confidentiality and security of their credentials and devices.

8. RISKS AND DISCLAIMERS

Users acknowledge that:
- crypto-assets are subject to significant volatility and risk of loss;
- transactions involving crypto-assets may be irreversible;
- regulatory treatment of services may change over time;
- technological systems may be subject to outages, delays or failures.
Neither Neoxpat nor the Platform provides financial, investment, legal or tax advice.

9. FEES AND COSTS

Fees, charges and costs applicable to services are determined by the relevant local service provider and disclosed in the applicable Local Terms or prior to execution of a transaction.
Neoxpat does not charge fees for mere access to the Platform, unless expressly stated.

10. SUSPENSION, RESTRICTION AND TERMINATION

Access to the Platform or specific functionalities may be suspended, restricted or terminated for reasons including security, compliance, risk management, suspected unlawful activity or regulatory requirements.
Termination of Platform access does not affect the user’s rights or obligations vis-à-vis local service providers under the applicable Local Terms.

11. INTELLECTUAL PROPERTY

All intellectual property rights in the Platform, including software, trademarks, content and design, are owned by or licensed to Neoxpat.
Users are granted a limited, non-exclusive, non-transferable and revocable license to use the Platform for personal purposes in accordance with these General Terms.

12. DATA PROTECTION AND PRIVACY

Personal data is processed in accordance with applicable data protection laws, including the GDPR where applicable, and the BNKA Privacy Policy.

13. LIMITATION OF LIABILITY

To the maximum extent permitted by law, Neoxpat shall not be liable for:
- acts or omissions of local service providers or third parties;
- losses arising from regulated services provided under Local Terms;
- indirect or consequential damages;
- losses caused by events beyond reasonable control.
Nothing in these General Terms excludes liability that cannot be excluded under mandatory law.

14. AMENDMENTS

Neoxpat may amend these General Terms from time to time. Updated versions will be published on the Platform. Continued use of the Platform constitutes acceptance of the amended terms.

15. GOVERNING LAW AND JURISDICTION

These General Terms are governed by the laws of Cyprus, without prejudice to mandatory consumer protection laws applicable in the user’s country of residence.